EFTA01104999.pdf

Fowler White Burnett ATTORNEYS AT LAW Espirito Santo Plaza Fourteenth Floor 1395 Brickell Avenue www.fowler-white.com Mr. Jeffrey Epstein March 21, 2011 301 East 66th Street Page I Suite 10 B New York, NY 10065 Ref.: LAS-23869-080743-457412 Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards and L.M. INVOICE Total Amount Due for this Invoice $ 123.786.25 Total Due $ 123,786.25 For Professional Services Through February 28, 2011 Date Description Atty Hours 01/28/11 Review and respond to emails; analyze options for privilege log issues; numerous calls LAS 1.25 with JLA; review draft letter to Judge Crow and attachments 01/31/11 Review correspondence. RGN 0.00 02/01/11 E-mail communications with Lilly Ann Sanchez Esquire re: accessibility of Charles CEK 1.75 Lichtman, Esquire and strategies relative to documents; e-mail communications with Joseph Ackerman, Esquire re: response letter to Jack Scarola, Esquire and continued follow up relative to privilege log; follow up relative to subpoena served upon DiScala; review of e-mail communication from the Honorable Robert Carney to all counsel relative to coordinating meeting time to review privilege log and documents; telephone conference with Lilly Ann Sanchez re: meeting with Judge Carney and counsel 02/01/11 Review Order denying stay from Judge Crow; review email from Special Master LAS 1.50 Carney re: privilege log issues; review draft response letter to Jack Scarola; confer with CEK and JLA; initial review of deposition transcripts and exhibits from bankruptcy matter; review numerous emails and pleadings filed. 02/01/11 Continue to review and analyze all Florida Federal cases, and Palm Beach Civil PMR 3.50 establish plaintiffs attorneys, defense attorneys, and compare with invoices provided by Atty. Critten 02/01/11 Continue to review and analyze all Florida Federal cases, and Palm Beach Civil PMR 1.50 establish plaintiff's attorneys, defense attorneys, and compare with invoices provided by Any. Critten 02/01/11 Review production from Wackenhut Corporation; Phone calls and emails with Dan JLA 2.00 Hershman regarding same (3); Emails with records from Karin S. at Wachenhut (2); Emails regarding motion hearings (3) 02/01/11 Preparation for Critton Depos regarding records needed; Emails from J. Carney on JLA 1.50 Privilege Log 0'2/01/11 Prepare Re-Notice of Hearing on Plantiffs Motion to Amend Complaint; On line search NAT 0.00 of Judge's instructions; Emails to Scarola's office regarding date 02/01/11 Prepare Notice of Hearing on Motion to Determine Whether Rehearing is appropriate NAT 0.00 0'2/01/11 Review and consider pleadings related to Defendants motion to reconsider SA 0.25 02/01/11 Review of exhibits to Stettin's Motion to Compel Q-Task's Depo and identify key MSG 4.00 documents regarding converstations between Adler and Rothstein; Follow-up on service of subpoena on At DiScala; Follow-up on outstanding discovery; Update Status Report Fowler White Burnett PA. EFTA01104999  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 2 Date Description Atty Hours 02/02/11 Online research for additional Palm Beach circuit court cases involving J. Epstein for PMR 1.00 comparison to Critten invoices 02/02/11 Draft email to Darren Indyke; review and respond to emails; review email from Gary LAS 1.00 Farmer; confer with JLA re: same; review and respond to emails; confer with CEK. 02/02/11 Summarize deposition of Katie Adler PMR 4.00 02/02/11 Telephone conference with Jeffrey Epstein re: current status, continued strategies CEK 1.75 relative to discovery, hearings, Judge Carney issues; e-mail communications with Joseph Ackerman, Esquire re: strategies with Farmer firm relative to privilege log; review of e-mail received from Jack Scarola, Esquire re: placing FWB on notice that Complaint and Answer to Counterclaim should be withdrawn; telephone conference with Joe Ackerman, Lilly Ann Sanchez, Esquire and Susan Aprill, Esquire re: postponement of deposition of AJ Discala per client's instructions; telephone conference with W. Scherer's office 02/02/11 Emails form J. Scarola (3); Revise Motion to Compel; Emails from Gary Farmer and J. JLA 1.50 Carney (2) regarding Privilege Log 02/02/11 Prepare for phone conferenc with G. farmer regarding Logs; Emails (7) regarding JLA 1.75 57.105 motion and begin research for response; Emails regarding settlement (4) 02/02/11 Emails to/from Jeffrey Epstein, Marty and Darren regarding Log issues (2); Emails JLA 0.50 regarding hearings and proposed orders (3) 02/02/11 Emails continue from J. Scarola (3); Revise Motion to Compel; Emails from Gary JLA 1.50 Farmer and J. Carney (2) regarding Log 02/02/11 (RRA Bankruptcy) Review Notice of Hearing and calendar hearing date for 2/3/11 on NAT 0.00 Expedited Motion Enforce #1320 Order, etc. 02/02/11 Finalize Notice of Taking Video Deposition of AJ Discala in New York for 2/22/11 and NAT 0.00 prepare for court filing 02/02/11 Emails from Scarola's office regarding Plaintiffs Motion to Amend and proposed order, NAT 0.00 Email to M. Nurik regarding same 02/02/11 Telephone call with Jessica at Critton's office regarding case status and request to NAT 0.00 locate report on M. Fisten 02/02/11 Continued work on readying for upcoming hearings (3) NAT 0.00 02/02/11 Calculate and calendar deadline pursuant to Judge Crow's instructions for special NAT 0.00 appointment 3/31/11 regarding Edwards' Motion for Reconsideration 02/02/11 Review of file to determine documents to be requested from Adler; Draft Schedule A of MSG 3.25 documents to be produced by Adler; Draft Subpoena for Deposition to be served on Adler; Teleconference with counsel for Adler re coordination of date for Adler's depo 02/03/11 Review and respond to emails; review response to Gary Farmer privilege log proposal; LAS 1.00 review and respond to numerous emails re: depositions and subpoenas duces tecum; confer with CEK and JLA. Fowler While Burnett P.A. EFTA01105000  Ref.: LAS-23869-080743-4574I2 March 21, 2011 Page 3 Date Description Atty Hours 02/03/11 Review of Qtask e-mails referred to by Charles Lichtman, Esquire; telephone CEK 5.50 conference with Jonathon Eva, Esquire of Broad and Cassel re: deposition of Al Discala and initial intention on filing of Motion for Protective Order, and potential for producing client on different date; preparation of e-mail to Jeffrey Epstein summarizing conversation with Jonathon Etra; follow up relative to Edwards' privilege defense with regard documents between himself and US Attorney's Office; e-mail communications with Jonathan Etra re: working towards new dates for deposition of Discala; follow up relative to service on Thane Ritchie and counsel's contesting of same; e-mail communications with Susan Aprill, Esquire re: finalizing new deposition date for Legamaro; receipt and review of letter from Johnson & Bell re: recap of events surrounding attempted service on Thane Ritchie; e-mail communications with Jeffrey Epstein re: Edwards/Adler e-mails; e-mail communications with Darren Indyke, Esquire re: Edwards/Adler e-mails; c-mail communications with Lilly Ann Sachcz, Esquire re: separate subpoena which has been prepared for records from records custodian of Adler; review of e-mail from Martin Weinberg, Esquire to Jeffrey Epstein re: Edwards Cross-Claim and opinion rendered by Judge Hoeveler on a General Master's findings on privilege 02/03/11 Review of status of legal precedent regarding awards for section 57.105 attorney's fees EEG 1.50 when non-movant has pending discovery. 02/03/11 Continue to summarize deposition of Katie Adler PMR 1.25 02/03/11 On line search regarding Judge Crow's instructions regarding special appointment NAT 0.00 hearings; Telephone call to Judge Crow's office regarding same; Telephone call back and forth between mediators regarding mediation (4) 02/03/11 Telephone call from Judge Crow's office regarding March dates for special NAT 0.00 appointment hearing; Email to/from Scarola's office regarding same (2) 02/03/11 Teleconference with counsel for Al DiScala re upcoming deposition; Communicate MSG 2.00 with Johnson & Bell re status of attempted service of subpoena on Thane Ritchie; Receive correspondence from Johnson & Bell outlining efforts to serve Ritchie; Distribute correspondence to team and update everyone as to schedule of depositions and upcoming hearings 02/03/11 Phone call with Darren I.; Prepare response regarding Edwards' Waiver; Emails with JLA 1.75 Marc Nurik regarding Motion to Amend (2); Emails regarding records requests (3); Email form Martin W; Emails regarding setting depositions (12) 02/04/11 Review Marty Weinberg emails; review docket and Abell case opinion issued by Judge LAS 3.00 Hoevelor; review and respond to emails re: counter proposal to Farmer; review comments; conference call with Gary Farmer and Special Master Carney re: privilege log issues; research re: alleged new demand letter sent; follow up with JLA. Fowler White Burnett P.A. EFTA01105001  Ref.: LAS-23869-080743-4574I2 March 21, 2011 Page 4 Date Description Atty Hours 02/04/I I E-mail communications with Lilly Ann Sanchez, Esquire re: Judge Canvey's request to CEK 6.00 our response to Gary Farmer, Esquire re: privilege log; telephone conference with Joseph Ackerman, Esquire re: response to Fanner; telephone conference with office of Gary Farmer, receipt and review of e-mail communication from Gary Farmer re: privilege log and Farmer's position to our response to their request; attendance at telephone conference with Gary Farmer, Brad Edwards, Esquire, Seth Lehr, Esquire, Lilly Ann Sanchez, Joe Ackerman and the Honorable Robert Carney re: privilege log; receipt and review of e-mail communication from Jack Scarola, Esquire re: claims made by Epstein; coordination of filing Motion for Sanctions in Bankruptcy proceedings; e-mail communications with Lesley Groff re: deposition schedule for February and March; receipt and review of Edwards' Notice of Filing page and Line Designations of entire deposition of Epstein taken March 17, 2010; follow up with Jonathan Etras, Esquire re: deposition of AJ Discola; receipt and review of e-mail communication from Judge Carney to all counsel re: suggestion of request for stay from Judge Ray to allow for Judge Crow to rule; receipt and review of Notice of Hearing on Epstein's Motion to Compel/Motion to Determine if Privilege Claims are Waived; receipt and review of Notice of Hearing on Epstein's Amended and Supplemental Motion of Plaintiff to Overrule Objections and Compel Defendant Edwards to Answer Questions and Appear for Further Deposition; receipt and review of e-mail communications between Gary Farmer, Esquire and Judge Carney re: suggested course of action; e-mail communications with Joe Ackerman, Lilly Ann Sanchez and Susan Aprill, Esquire re: William Scherer, Esquire, discussions of recusing Judge Carney; receipt and review of e-mail communication from Jack Scarola to Judge Carney re: suggestion course of action; e-mail communications with Joe Ackerman re: Jenne Affiavit and Razorback Complaint to be reviewed by Henry Burnett, Esquire and Esther Galicia, Esquire relative to their opinions 02/04/11 Detailed review, study and analysis of status of legal precedent in Florida and Federal EEG 2.00 Courts, and preparation of memorandum regarding whether interrogatories which are objected to, and objections are sustained, count towards number limit on interrogatories. 02/04/11 Review, study and analysis of five (5) reported U.S. v. Abbell decisions issued by Judge EEG 0.50 William Hoeveler. 02/04/11 Detailed review, study and analysis of status of legal precedent in Florida regarding EEG 5.00 whether pendency of records or discovery dispute is grounds for staying 21-day safe harbor period under Section 57.105 or is otherwise a defense to a Motion for Section 57.105 Attorney's Fees; possible existence of conflict of interest due to Motion for Section 57.105 Attorney's Fees. 02/04/11 Review of file for preparing updated status report to client; Follow-up with NY law MSG 3.00 firm re Procedure for obtaining records from Al DiScala; Follow-up with Johnson & Bell in Chicago re Service of Process on Thane Ritchie; Update Status Report, Deposition Schedule and Schedule of Hearings 02/04/11 Emails regarding 57.105 issues; Begin research on 57.105 issues (5); Emails to/from JLA 4.75 and regarding R. Carney (6); Emails to/from J. Scarola (6); Emails to/from Gary Farmer (8); Conference call with Gary Farmer, R. Carney, Chris Knight and Lilly Sanchez; Emails regarding depositions/duces tecum (13); Emails from darren I./client (2); Research regarding attorney/crime exemption fund 02/04/11 (DK v. Epstein- new case) Emails and correspondence regarding new claim (2) JLA 0.25 02/04/11 Emails and phone calls (2) with Jessica at Critton's office JLA 0.25 Fowler White Bumett P.A. EFTA01105002  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 5 Date Description Atty Hours 02/06/11 E-mail communications with Jeffrey Epstein re: preparation of letter to Judge Carney CEK 1.00 relative to Edwards' intentions, court orders ignored, threats to firm, etc.; telephone conference with Lilly Ann Sanchez, Esquire and Joseph Ackerman, Esquire re: coordination of letter to Judge Carney; 02/07/11 Review and respond to numerous emails from Special Master Carney and Gary Farmer LAS 2.00 and Jack Scarola; review new demand letter, analyze defenses to same; review and respond to emails; conference call with team re: status and options; numerous update emails to JEE and Darren Indyke. 02/07/11 Attendance at strategy conference with Lilly Ann Sanchez, Esquire, Joseph Ackerman, CEK 5.00 Esquire and Susan Aprill, Esquire re: outcome of telephonic meeting with Judge Carney and opposing counsel, Judge Canvey's suggestions, potential for recusal of Judge Carney, involvement of William Scherer, Esquire, privilege log/necessary documents, upcoming depositions, upcoming hearing, recent rulings in similar matters, going forward strategies; e-mail communications with Jeffrey Epstein re: status of AJ Discala deposition, upcoming telephone conference with Jonathan Etra, Esquire, counsel for Discala; review of draft outline for deposition of generic investor witness; e-mail communications with Lesley Groff re: deposition and travel schedule; telephone conference with Jonathan Etra re: no response from client regarding agreement to deposition; follow up relative to Judge Crow and duces tecum portion of subpoena; e- mail communications with Lilly Ann Sanchez re: confirmation that Bill Scherer will be defending Dean ICretschmar's deposition; e-mail communications with Susan Aprill re: communcations with Nina Stillman, Esquire, counsel for Michael Legamaro; review of proposed schedule of documents to be produced by investors at their depositions; e- mail communications with Susan Aprill re: 5 CD's received from Conrad Scherer, documents received from Bill Scherer and considerable mention of DiScala in same 02/07/11 Team conference SA 1.25 02/07/11 Communication with Maxine Streeter at Conrad Scherer and begin review 5 CDs of SA 4.00 documents turned over 02/07/11 Telephone conference with Nina Stillman SA 0.25 02/07/11 Summarize deposition of Leon Brauser in RRA Bankruptcy matter. PMR 5.50 02/07/11 Work on depositions questions; Emails to/from J. Scarola (4); Phone call with J. JLA 1.00 Scarola 02/07/11 Status conference call regarding case preparation ILA 1.25 02/07/11 Revise subpoena for records; Email from Gary Farmer (1); Emaimls regarding JLA 1.50 depositions (7); Emails from Jeffrey Epstein/Marty W. (4); Emails regarding trial preparation; Prepare for Kreschmar deposition 02/07/11 Telephone call from/with Amy at Orange Reporting regarding hearing on 2/8/11 (2); NAT 0.00 Entail to Orange Reporting regarding same 02/07/11 Continue getting file ready for two hearings 2/8/11; Prepare Order for hearing (2); NAT 0.00 Prepare four more orders for other hearings as well 02/07/11 Review of file re updating deposition schedule, hearing schedule, and status report; MSG 3.75 Communicate with NY law firm re requirements for obtaining documents from DiScala in NY; Update status report; Update deposition schedule; Update schedule of hearings; Participate in team phone conference call 02/08/11 E-mail communications with Lilly Ann Sanchez, Esquire re: names from U.S. CEK 0.50 Attorney's Office, Palm Beach Police Department, FBI and State Attorney's Office Fowler White Burnett P.A. EFTA01105003  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 6 Date Description Atty Hours 02/08/11 Received Notice of Hearing on Plaintiffs Motion to Determine Whether Rehearing is MLF 0.00 Appropriate calendar and notify interested parties. Received from Bankruptcy Court Motion to Determine Whether Rehearing is Appropriate; calendar and notify parties. 02/08/11 Confer with Maxine Streeter regarding history and prepare for deposition of Dean SA 1.75 Kretschmar and other investors 02/08/11 Continue to summarize deposition of Leon Brauser in RRA bankruptcy matter PMR 1.50 02/08/11 Summarize deposition of Michael Brauscr in the RRA Bankruptcy matter. PMR 4.00 02/08/11 Emails regarding Razorback documents O0); Emails regarding deposition scheduling JLA 3.25 (10); Emails regarding trustee search for records (3); Attend hearing on Motion to Determine Status of Motion for Rehearing 02/08/11 Review of file re identifying the names of the individuals in the FBI, USAO, & State MSG 4.25 Atty's Office in Palm Beach County for providing info to Lichtman to obtain documents responsive to supplemental subpoena for records; Follow-up on status of discovery and depositions 02/09/11 Review and respond to emails; update subpoena to Herb Stettin; confer with Chuck LAS 1.25 Lichtman re: same; review Leon Brauser deposition; review Abbell docket and opinions on crime fraud; review and respond to numerous emails from Gary Farmer and Special Master Carney; confer with JLA re: same. 02/09/11 Telephone conference with Lilly Ann Sanchez, Esquire re: deposition of Michael CEK 2.00 Legamaro; review of deposition summary of Leon Brauser; receipt and review of executed Order on Plaintiffs Motion to Determine if Rehearing is Appropriate; telephone conference with Jonathan Etra, Esquire re: deposition of AJ Discala; e-mail communications with Jonathan Etra re: agreement relative to resetting of Discala; e- mail communications with Joseph Ackerman, Esquire re: deposition of Discala and area of questioning; receipt and review of e-mail communications between Gary Farmer, Esquire and the Honorable Robert Carney re: privilege log, providing of same to Judge Crow only and rulings made; receipt and review of e-mail communication from Gary Farmer to all counsel re: work on privilege log and review of documents 02/09/11 Telephone conference with Maxine Streeter SA 1.00 02/09/11 Telephone conference with William Hobbs, attorney to Thane Ritchie. SA 0.50 02/09/11 Review documents to prepare for investor depositions. SA 2.00 02/09/11 Case preparation regarding document review; Review deposition of Leon Brauser; JLA 2.00 Preparation for deposition (continued) 02/09/11 Emails from G. Farmer (4); Email from J. Carney; Emails regarding Discala's JLA 0.75 deposition (2) 02/09/11 Communicate with Chicago law firm re service of subpoena on Thane Ritchie; Begin MSG 2.75 identifying key documents in preparation for deposition of Dean Kretschmar and upcoming depositions of Michael Legamaro & Thane Ritchie; Communicate with opposing counsel re dates of availability for deposition of Michael Legamaro 02/10/11 Review and respond to emails; prepare for Dean Kretchmar deposition; confer with LAS 2.00 Susan Aprill re: same; review emails re: Discala deposition from his counsel Jonathan Etra; contact lEE re: same. 02/10/11 Receipt and review of Notice of Cancellation of Hearing - UMC on Plaintiffs Motion CEK 0.50 to Amend Complaint; e-mail communications with Jeffrey Epstein re: proposed new dates for deposition of Al Discala and availability for same 02/10/11 Continue to draft Depo summary of Michael Brauser PMR 1.00 02/10/11 Prepare memo regarding investors; prepare for Dean Kretschmar deposition; examine SA 5.00 documents turned over. Fowler White Burnett P.A. EFTA01105004  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 7 Date Description Atty Hours 02/10/11 Emails regarding Discala deposition (8); Email from Gary Farmer; Email to/from J. JLA 0.75 Carney (2) 02/10/11 Review Edwards' Motion to Compel regarding mediation and Notice of Hearing; JLA 0.50 Review Motion to Compel Exhibit List and Notice of Hearing 02/10/11 Review and analyze extensive documents received from Conrad Sherer for reference to PMR 2.50 Mr. Kretschmar in preparation of deposition of Kretschmar 02/10/11 Assist SA with depo prep for Dean Kretschmar, Review Conrad Scherer documents to MSG 5.00 identify any documents relating to Dean Kretschmar 02/11/11 Prepare for and attend deposition of Dean Kretschmar in Ft. Lauderdale. LAS 6.00 02/11/11 Depose Dean Kretschmar and confer following on strategy for DiScala and Legomaro SA 4.00 and revise memo 02/11/11 Review and analyze transcript of Roger Stone in preparation for summary of deposition PMR 0.50 02/11/11 Summarize deposition of Roger Stone PMR 2.00 02/11/11 Review emails regarding privilege log matters; Letter to Judge Carney; Letter to Gary JLA 4.00 Farmer, Prepare Motion to Continue and Notice of Hearing; Case preparation 02/11/11 E-mail communications with Darren Indyke, Esquire and receipt and review of list of CEK 1.00 search terms; e-mail communications with Darren Indyke re: deposition of AJ Discala and review of disks received from Scherer's firm; e-mail communications with Susan Aprill, Esquire re: notification that certain documents provided from Scherer are "work product" and will be requested to be returned, discussion of complete review of documents; receipt and review of interoffice memorandum on information from investors' counsel relative to Dean Kretschmar and Thane Ritchie; telephone conference with B. Edwards 02/11/11 Review letter to Judge Carney from J. Ackerman responding to G. Farmer SA 0.25 02/11/11 Review and analyze deposition of Roger Stone in preparation of drafting depo summary PMR 0.25 02/11/11 Telephone call from/to Julieann R. at Searcy Denney regarding deposition Schedule (5) NAT 0.00 02/11/11 Email to/from Julieann at Scarola's office rgarding deposition dates for RC/Wackenhut NAT 0.00 Corporation; Review of file reflecting this was already done by Scarola and he is setting records custodian depostions on Wackenhut Corporation 02/11/11 Update Timeline of Events based on information learned at Kretschmar's deposition; MSG 4.00 Perform docket search for a lawsuit filed by Kretschmar against Thane Ritchie in IL; Communicate with Chicago law firm re obtaining copy of pleadings in the IL lawsuit; Update status report and prepare for team conference to discuss status of pending items and additional items needed 02/12/11 Revise memorandum on interviews regarding investors SA 1.00 02/13/11 Consider how investor information advances case and detail explanation in emails SA 0.50 02/13/11 E-mail communications with Susan Aprill, Esquire re: conversations by Rothstein to CEK 0.50 investors, effect on the case, effect with Brad Edwards 02/14/I1 Review responses to letter to Special Master Carney; review options; team conference LAS 3.00 call re: status of outstanding issues; review summary memorandum re: investor depositions/information and forward same; numerous emails with Gary Fanner and Special Master Carney; review motion for sanctions. Fowler White Burnett P.A. EFTA01105005  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 8 Date Description Atty Hours 02/14/11 Attendance at telephone conference with Lilly Ann Sanchez, Esquire, Joseph CEK 5.25 Ackerman, Esquire and Lilly Ann Sanchez, Esquire re: upcoming deposition of Michael Legamaro, updated timeline of events, status of 57.105 Motion, new dates for deposition of AJ Discala, review and summary of bankruptcy depositions, review of Conrad Scherer documents (relative to Discala and other investors), review of documents from Gary Farmer, Esquire, upcoming deposition of Thane Ritchie, response to Motion to Amend to Add Punitive Damages; telephone conference with Jonathan Etra, Esquire re: new dates of availability for Discala deposition; receipt and review of Berenfeld Spritzer Shecter & Sheer's Adoption of Chapter 11 Trustee's Designation of Additional Items to be Included in the Record on Appeal; receipt and review of letter from Judge Robert Carney to Joseph Ackerman re: Motion for Protective Order, privilege log and scheduling of evidentiary hearing; receipt and review of e-mail communications from Jack Scarola, Esquire re: availability for hearing; receipt and review of e-mail communications from Gary Farmer, Esquire re: availability for hearing; e-mail communications from Lilly Ann Sanchez to Judge Carney re: agreement of parties and review of documents and log; receipt and review of e-mail communication from Gary Fanner to Judge Carney re: advising of appearance for hearing; receipt and review of e-mail communication from Judge Carney to Lilly Ann Sanchez re: confirmation of hearing; receipt and review of e-mail communication from Jonathan Etra re: canceling of subpoena, work towards new dates for deposition, notice on formal meet and confer; telephone conference with Jonathan Etra re: dates for Discala deposition; e-mail communications with Jonathan Etra re: request for cancellation of presently scheduled deposition, agreement to work towards new date of availability 02/14/11 Continue to summarize the deposition of Roger Stone PMR 0.75 02/14/11 Continue to draft depo summary of Roger Stone PMR 1.00 02/14/11 Review and analyze deposition transcript of Russell Adler in preparation of deposition. PMR 0.75 02/14/11 Review and analyze files for exhibits to bankruptcy depositions PMR 0.75 02/14/11 Continue deposition summary of Roger Stone PMR 0.75 02/14/11 Begin drafting Deposition Summary of Russell Adler PMR 1.50 02/14/11 Review pleadings; court filings. RGN 0.00 02/14/11 Prepare hearing files and compile documents on Edwards' Motion to Compel; Prepare NAT 0.00 Order on Edwards' Motion to Compel; Prepare Order on Epstein's Motion to Continue Jury Trial 02/14/11 Email on meeting 2/16/11 at Scarola's office relating to court reporter covering NAT 0.00 meeting; C 02/14/11 Email from Emails regarding special master letter (5); Emails JLA 1.00 regarding Wackenhut depositions (2); Emails regarding Conrad/Scherer documents and depositions (2); Emails regarding agreement 02/14/11 Status conference for case preparation JLA 1.00 02/14/11 Emails regarding hearing on Motion for Protective Order (9); Email from M. Pirrotta JLA 4.00 regarding motion hearings (s); Work on Motion for Sanctions and hearing preparation before special master 02/14/11 Team call SA 1.00 Fowler White Burnett P.A. EFTA01105006  Ref.: LAS-23869-080743-457412 March 21, 2011 Page 9 Date Description Atty Hours 02/14/11 Review of file re updating discovery and status report; Update To-Do List; Participate MSG 3.25 in Team Conference Call with LAS, CEK, LA & SA; Communication with Chicago law firm re deposition of Thane Ritchie and Michael Legamaro; Communication with NY law firm re deposition of AJ DiScala; Review of documents produced by Conrad Scherer re Al Discala 02/15/11 Review and respond to emails; prepare for hearing with Special Master Carney; review LAS 2.50 motion for sanctions; finalize and forward summary memorandum; review transcript of Dean Kretschmar and forward; confer with CEK re: strategy for hearing with Special Master Carney. 02/15/11 Continue to draft depo summary of Russell Adler PMR 2.00 02/15/11 Per Mr. Ackerman's request, checked Bankruptcy Court Docket; forwarded appeal MLF 0.00 documents filed in the case for his records. 02/15/11 Continue to draft depo summary of Russell Adler PMR 2.00 02/15/11 Emails from Scarola's office (3) and email to Scarola's office regarding deposition NAT 0.00 schedule for RC/Wackenhut by Scarola's office on two depositions 02/15/11 Emails from Scarola's office (2) regarding deposition schedule; Telephone call NAT 0.00 from/with court reporter regarding 2/16/11 hearing 02/15/11 Finalize hearing file and prepare for 2/16/11 hearing; Prepare Consent for client to NAT 0.00 review and execute regarding Motion to Continue Trial 02/15/11 Put Service List together; received Motion for Sanctions and Exhibits from Ackerman MLF 0.00 to file with the Bankruptcy Court; filed it (D.E. 1442); prepared Notice of Withdrawing Document D.E. 1441 and filed it with the Court - Motion for Sanctions previously filed that needed corrections. 02/15/11 Continue to work on Motion for Sanctions regarding privilege log; Prepare exhibits for JLA 10.00 same; Legal research for same; Preparation for Motion to Continue Trial and emails to/from J. Scarola's office regarding same (4); Preparation for hearing before Special Master Carney regarding Motion for Protective Order, Legal research and preparation of exhibits for same and emails regarding same (7); Emails from Special Master Carney regarding hearing protocol; Emails regarding records custodian depositions (4); Emails to/from Jeffrey Epstein and Darren regarding Motion to Continue (4) 02/15/11 Review and comment on motion for sanctions SA 0.50 02/15/11 Attention to deposition issues SA 0.50 02/15/11 Review pleadings in Bankruptcy Court and correspondence. RGN 0.00 02/15/11 Received and reviewed e-mail from Susan Aprill re Epstein's Motion for Sanctions. RGN 0.00 02/15/11 Review Conrad Scherer documents to identify any documents to or referencing Brad MSG 2.25 Edwards in preparation for hearing with Special Master Carney re privilege waiver 02/16/11 Received from the Bankruptcy Court Order Granting Trustee's Motion to Fix and MLF 0.00 Compel Payment by Qtask and Scheduling Order; calendar all deadlines and forward to all parties-in-interest. Received from the Bankruptcy Court Joint Ex Parte Motion for Protective Order re documents requested to Razorbak. Fowler White Burnett P.A. EFTA01105007  Ref.: LAS-23869-080743.457412 March 21, 2011 Page 10 Date Description Atty Hours 02/16/11 Preparation for, travel to and attendance at "hearing" before the Honorable Robert CEK 8.00 Carney relative to privilege log, Motion for Protective Order, etc.; post-hearing meetings with Lilly Ann Sanchez, Esquire and Joseph Ackerman, Esquire re: strategies, including communications with Chuck Lichtman, Esquire; e-mail communications with Lilly Ann Sanchez re: outcome of conversation with Chuck Lichtman, potential for direct contact with Herb Stettin; attendance at meeting with client; telephone conference with Chuck Lichtman re: documents, privilege log; receipt and review of e- mail from Judge Carney re: documents to be provided by Chuck Lichtman and procedure for review of same; e-mail communications with Lilly Ann Sanchez and Joe Ackerman re: potential actions by Judge Carney; e-mail communications with Darren Indyke, Esquire re: communications with Chuck Lichtman; e-mail communications with Jonathan Etra, Esquire re: new dates of availability for deposition of Al Discala 02/16/11 Prepare for, travel to and attend meeting with Special Master Carney in Palm Beach; LAS 8.00 review and respond to numerous emails from Chuck Lichtman re: response to subpoenas on communications with law enforcement; review and respond to emails from Farmer re: same; confer with Darren Indyke; review pleadings filed in Judge Marra matter; confer with CEK and ILA; follow up conversation with Chuck Lichtman; forward documents for review. 02/16/11 Review emails and portion of Kretschmar transcript and telephone conference with Joe SA 0.50 Ackerman 02/16/11 Locate and identify Exhibits to Deposition transcripts in RRA Bankruptcy PMR 0.50 02/16/11 Continue to summarize deposition of Russell Adler in RRA Bankruptcy depositions PMR 1.75 02/16/11 Continue to summarize deposition of Russell Adler in RRA Bankruptcy depositions PMR 1.00 02/16/11 Continue to summarize deposition of Russell Adler in RRA Bankruptcy depositions PMR 1.00 02/16/11 Various emails from/to regarding transcript regarding 2/16/2011 hearing on Epstein's NAT 0.00 Motion to Continue Trial (2); Telephone call to/with Orange Reporting regarding 2/17/2011 hearing transcript and email regarding same 02/16/11 Prepare for and attend hearing on Motion to Continue Trial; Prepare for and attend JLA 8.00 hearing before Special Master Robert Carney; Assist in preparation of letter with exhibits to C. Lichtman regarding documents on second subpoena; Phone calls and emails regarding Lichtman letter (14) 02/16/11 Emails to/from Jack Scarola regarding Wackenhut depositions (3); Emails to Dan JLA 0.50 Hershman at Wackenhut regarding same; Email from Judge Carney regarding trustee documents and hearing (2) 02/16/11 Review emails between Farmer/Lehrman and Charles Lichtman (4) JLA 0.25 02/16/11 Review of Conrad Scherer documents to identify any documents relating to DiScala MSG 1.00 02/17/11 Review and respond to emails re: new documents from Chuck Lichtman; confer with LAS 1.50 Chuck Lichtman; confer with JEE and Darren Indyke; confer with CEK and JLA update ere: motion to continue; review transcripts and forward. Fowler White Burnett P.A. EFTA01105008  Ref.: LAS-23869-080743-4574I2 March 21, 2011 Page 11 Date Description Atty Hours 02/17/I I Review of Court documents relative to Thane Ritchie and lawsuit in Chicago, IL; e- CEK 3.00 mail communications with Jeffrey Epstein re: Judge Camcy's proposed plan of action relative to documents to be provided by Chuck Lichtman, Esquire; e-mail communications with Joseph Ackerman, Esquire and Lilly Ann Sanchez, Esquire re: strategies regarding response to Judge Carney that documents are not privileged on their face and do not need to be turned over to Defendant for log or review and further strategies regarding contact with Judge Herb Stettin; receipt and review of c-mail communication from Gary Farmer, Esquire to Judge Carney re: disagreement with plan of action; telephone conference with Joe Ackerman and Lilly Ann Sanchez re: response to Judge Carney and our disagreement with plan of action; receipt and review of transcript of proceedings on Plaintiffs Motion to Continue Trial dated February 16, 2011; receipt and review of executed Agreed Order Granting Plaintiffs Motion to Amend Complaint; receipt and review of transcript of proceedings before the Honorable David Crow of February 17, 2011; e-mail communications with Lilly Ann Sanchez re: continued follow up for contact with Judge Stettin; continued follow up with Chuck Lichtman; review of deposition summary of Leon Brauser; telephone conference with C. Lichtman 02/17/11 Review correspondence and pleadings from the Bankruptcy Court. RGN 0.00 02/I7/1 I Attend hearing regarding Edwards' Motion to Compel Designation of Exhibits; Review JLA 2.00 Order regarding Motion to Amend Complaint; Begin work on Confidentiality Agreement 02/17/11 Emails to/from Jeffrey Epstein regarding costs for privilege review (4); Emails JLA 1.25 regarding upcoming depositions and deposition summaries (2); Emails regarding production of records from trustee (9); Emails to/from Robert Carney regarding new records production (2) 02/17/11 Review, revise and modify Michael Brauser deposition to add summary of exhibits. PMR 1.00 02/17/11 Continue working on identifying documents relating to AJ Discala in preparation for MSG 3.00 his upcoming deposition 02/17/11 Order on Motion to Amend Complaint docket deadline; Calendar Scarola's Notice NAT 0.00 Taking Deposition of Wackenhut witnesses (2) for depositions 2/25/11 and 2/28/11 02/17/11 Email to J. Scarola regarding status of Confidentiality Agreement NAT 0.00 02/17/11 Email to M. Nurik's office regarding 2/17 hearing transcript; Email from/to Lilly NAT 0.00 Sanchez regarding same; Emails regarding 2/16 hearing transcript on Motion to Continue Trial 02/18/11 Receipt and review e-mail communication from The Honorable Robert Carney re: CEK 3.00 recent ruling by Judge Ray on Berger Singerman/Qtask; e-mail communications with Lilly Ann Sanchez, Esquire, Joseph Ackerman, Esquire and Susan Aprill, Esquire it: Judge Carney's comments and our response that these documents do not seek privilege, coordination of update relative to Dean Kretschmar, coordination of list of additional deponents; follow up on depositions of Thane Ritchie and Al Discala; e-mail communications with Jonathan Etra, Esquire re: deposition of Discala in New York or Miami; e-mail communications with Joe Ackerman re: deposition of Wackenhut; coordination of proposed schedule relative to privilege log; follow up relative to contact with Chuck Lichtman, Esquire; e-mail communications with Darren Indyke, Esquire it: contact with Chuck Lichtman and permission to contact Judge Stettin; receipt and review executed order on Defendant Edwards' Motion to Compel; receipt and review of executed Order Granting Plaintiffs Motion to Continue Trial and Scheduling Case Management Conference; telephone conference with H. Stettin's office Fowler White Burnett P.A. EFTA01105009